Case Preview: Montgomery v. Caribe Transport II, LLC | When a Federal Firewall Blocks Broker Blame

Montgomery v. Caribe Transport II, LLC | Oral Argument: 3/4/2026 | Case No. 24-1238 | Docket Link: Here

Question Presented: Whether the Federal Aviation Administration Authorization Act preempts state common-law tort claims against brokers for negligently selecting motor carriers or drivers whose vehicles subsequently cause accidents.

Overview: Trucking broker liability case determines whether federal deregulation law blocks state tort claims for negligent hiring practices that result in highway accidents with severe injuries.

Posture: Seventh Circuit affirmed preemption; Ninth Circuit rejected preemption; circuit split.

Main Arguments:

• Montgomery (Petitioner): (1) Federal safety exception explicitly preserves state tort claims against broker negligent selection; (2) Fair interpretation requires consistent broad reading of both preemption provision and safety exception; (3) Longstanding common law negligent hiring claims predate federal trucking regulation

• C.H. Robinson/Caribe (Respondents): (1) Federal law preempts broadly any state regulation of broker services and selection decisions; (2) Safety exception applies narrowly only to direct motor vehicle operation regulation; (3) Comprehensive federal regulatory scheme provides adequate safety oversight

Implications: Montgomery victory preserves state tort accountability for broker hiring decisions, incentivizing highway safety through market liability. Respondent victory eliminates broker accountability for negligent selection, potentially reducing safety screening while limiting victim compensation options for trucking accidents.

The Fine Print:

• 49 U.S.C. § 14501(c)(1): "a State may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier...or any motor private carrier, broker, or freight forwarder with respect to the transportation of property"

• 49 U.S.C. § 14501(c)(2)(A): the preemption provision "shall not restrict the safety regulatory authority of a State with respect to motor vehicles"

Primary Cases:

• Dan's City Used Cars v. Pelkey (2013): Phrase "with respect to the transportation of property" in FAAAA preemption provision "massively limits" federal preemption scope, requiring direct connection to transportation services

• Miller v. C.H. Robinson Worldwide (9th Cir. 2020): State negligent hiring claims against motor carrier brokers fall within FAAAA safety exception because they represent state authority to regulate safety through common-law tort claims